Combustible Dust

Wood dust has become an issue that is at the forefront of today's public policy rule makers.

However, before this rule becomes effective it must pass several hurdles. First, it must be submitted to an SBREFA panel organized under the "Small Business Regulatory Enforcement Fairness Act of 1996". This panel will look at the impact on small businesses. After that a final proposed rule will be posted for public comments. The time for the issue of final rule could be a long time out.

The WMMA Dust Task Force encourages you to get involved when the final proposed rule is issued and give comments to sections that may affect your business and the business of your customers.

NFPA 664 Combustible Dusts Overview is now available!

The National Fire Protection Association - NFPA® has issued several standards and it can be quite difficult to get a good overview of these standards. The WMMA Dust Task Force has developed this tool to help you to get to get an overview of the requirements set out in the NFPA standards. It is important for the user to understand that in each case the user must consult the applicable standard to assure the particular facility/process being assessed complies with the correct standard.

The technical committee for NFPA 664 held a meeting in Atlanta, GA on October 12 and13 to review the public comments on the proposed changes to the 2011 edition. The changes that were proposed during the meeting will be posted on the NFPA website on or about 2/25/2011.

Proposed Combination of Standards
Please see the attached two page memo (Seeking Input on Combining Documents).

Read the WMMA comment letter to NFPA.

Many experts consider the combination of NFPA 664 with other standards will not be in the interest of the woodworking industry because it would likely eliminate the exemption for the small wood shop as defined in 1.1.2 and the goal to provide for a facility that is "reasonably protected...in a cost effective manner" as stated in 4.1 of the standard.

Combustibility
First, the Occupational Safety and Health Administration (OSHA) initiated rulemaking on combustible dust in October 2009. Stakeholders are currently providing feedback.

In addition, the National Fire Protection Association (NFPA) has two standards currently in review cycle: NFPA 654, the Standard for the Prevention of Fire and Dust Explosions for the Manufacturing, Processing and Handling of Combustible Particulate Solids, and NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities.

Health Impact
The International Agency for Research on Cancer (IARC) recently made a causal link between wood dust and sinonasal and nasopharyngeal cancer. As a start of the regulatory activity, the State of California, which has been looking at wood dust as a potential item that would require labeling, is considering whether to lower permissible exposure limits.

Resources
Below are some links to materials that would be helpful in understanding the issues.

• New Resource! This OSHA presentation provides the basic knowledge to help:
  
  • Recognize some of the various types of combustible dust
  • Identify sources of ignition for combustible dust
  • Determine inspection evaluation methods
  • Describe the National Emphasis Program on combustible dust, including recent revisions
    
    
• 2010 January UPDATE - WOOD DUST EXPOSURE LAWSUITS (Note that the Alabama litigation that is discussed has been settled with no liability to the named remaining parties.)
  
  
• Report on the OSHA stakeholder meeting on December 14, 2009, "Manufacturers voice concerns at OSHA combustible dust meetings"
  
  
• Combustible Dust: Regulatory and Legal Challenges
  Presentation by Adele L. Abrams at the Small Business Legislative Counsel roundtable, Washington, DC, November 2009
  
  
• Combustible Dust: An Explosive Issue
  Presentation by Jamie Scott, Air Handling Systems, at The Dollars and Sense of Going Green conference, Schaumburg, IL, November 2009
  
  
• Combustible Dust Update: OSHA's Preliminary Rulemaking on Dust is Underway
  A November 2009 article by legal consultant Keller and Heckman LLP
  
  
• OSHA's Advance Notice of Proposed Rulemaking, October 21, 2009
  
  
• NFPA 654, Standard for the Prevention of Fire and Dust Explosions for the Manufacturing, Processing and Handling of Combustible Particulate Solids
  
  
• NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
  
  
• IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, IARC Monograph, Vol 62

WMMA has formed an Industrial Dust Task Force to monitor the situation. In addition, WMMA is a member of the Inter-Industry Wood Dust Coordinating Committee (IWDCC), organized by the American Forest & Paper Association (AF&PA) to help ensure that the woodworking equipment and the wood processing industry and related industries are represented in these public policy discussions and decisions.